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INTERROGATORY NO. 16:Identify each communication that you had with

Defendants William N. Matthews or the Solid Rock Church that you contend support

any of the allegations made in your Complaint.

ANSWER NO. 16:Plaintiff cites two sets of documents where the answer to this

question can be found. The first set of documents is located on Plaintiffs' Internet site of

http://www.james417.organd the second set of documents is located in a small box at

Plaintiff's office. Defendants are referred to Plaintiffs' ANSWER No. 1to Defendants

FIRST SET OF REQUESTS FOR DOCUMENTSfor further information concerning these

documents. All facts concerning this particular question can be easily ascertained by

examining these two sets of documents.

INTERROGATORY NO. 17:Identify all documents that refer to or relate to your

responses to these interrogatories.

ANSWER NO. 17:Plaintiffs' answer is the same as ANSWER No. 16

Dated: August 27, 1999

Signed:

_____________________________________
Edward G. Palmer, Plaintiff

Address:

15548 95th Circle NE
Otsego, Minnesota 55330
(612) 441-3440
(612) 441-7174 Fax